04 February 2010

Pension Scheme Record Keeping By Ian Hill

Following extensive research and engagement with pension providers and employers during 2009, the Pensions Regulator has built on guidance published last year, which provided a framework for the clarification and assessment of member records.

In the current environment many employers want to look at the costs of their pension schemes so good governance is important in the economic downturn. A number of employers have taken steps such as closing to new members or new accrual, or have considered de-risking measures such as buy-outs. A prior condition for the successful achievement of these steps is having good data. In contrast, having poor data, or being uncertain about data quality, can add significant costs and delays, and can prevent successful de-risking.

The Pensions Regulator has published a consultation setting out standards for member records and requiring schemes that fall short to take steps to improve their performance. Trustees and those responsible for administering workplace pensions will need to improve standards of record keeping.

Take-up of this guidance - which set out the common data schemes were required to hold - fell below the levels expected. Only 19% of schemes surveyed had checked that they had all the fundamental common data. Of these, some 53% appeared to be missing more than one item of this data.

Under revised proposals, it will now be a requirement for all schemes to maintain high-quality standards of data.

The Regulator proposes to set targets for the accuracy of the common data which schemes must hold. The Regulator also proposes to review performance of schemes. Where schemes fail to have adequate plans in place to resolve data issues, the Regulator will require them to improve.

Good record-keeping applies to all schemes, whether trust-based or contract-based. In respect of contact-based arrangements, the Pensions Regulator works closely with the Financial Services Authority to improve standards and take corrective action where necessary.

Poor record-keeping can lead to significant additional costs for schemes, with the potential effect of reduced benefits for members.

The Regulators comments are timely as automatic enrolment will bring millions of people into pension saving for the first time, increasing the volumes of member data held. This makes it all the more important that schemes put their records in order.

Poor record-keeping can result in extra costs to a scheme in areas such as administration, error correction, claims from members, wind-ups or buy-outs.

As part of the 2012 pension reforms, obligations on record keeping form part of compliance regulations which have been laid before Parliament.

The consultation, which lasts 12 weeks, can be viewed on the regulator's website: http://www.thepensionsregulator.gov.uk/

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